United States v. Washington, No. 24-5124 (6th Cir. 2024)
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Brian Washington, a federal prisoner, pleaded guilty in 2013 to possession of crack cocaine with intent to distribute and using and carrying a firearm in a drug trafficking crime. Due to prior convictions, he was classified as a career offender and sentenced to 280 months in prison. Washington did not appeal his convictions, and his post-conviction relief claims were unsuccessful. He has since filed four motions for compassionate release, all of which were denied by the district court.
The United States District Court for the Eastern District of Kentucky denied Washington's fourth motion for compassionate release. Washington appealed, arguing that the disparity between crack and powder cocaine sentences, his declining mental health, age, and rehabilitation efforts constituted extraordinary and compelling reasons for his release. The district court found these arguments unpersuasive and denied the motion.
The United States Court of Appeals for the Sixth Circuit reviewed the district court's denial for abuse of discretion. The court held that the disparity between crack and powder cocaine sentences does not constitute an extraordinary and compelling reason for compassionate release. The court also noted that Washington's claims regarding his mental health and age were forfeited as they were not raised in the district court. Additionally, the court found that rehabilitation alone is not an extraordinary and compelling reason for release, as per 28 U.S.C. § 994(t). Consequently, the Sixth Circuit affirmed the district court's denial of Washington's motion for compassionate release.
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